Anti-Money Laundering (AML) Policy & Procedures Statement

1. Introduction

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Evendough Holdings Ltd., is committed to combating money laundering, terrorist financing, and other financial crimes.We maintain a robust Anti-Money Laundering (AML) framework tailored to meet the legal and regulatory requirements of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and all related regulations. 

Our AML/CTF policies and procedures align with FINTRAC guidance, applicable Canadian legislation, and internationally recognised standards, including the Financial Action Task Force (FATF) Recommendations. Evendough applies a risk-based approach to compliance and maintains controls appropriate to its business model, services, and regulatory obligations.
 

2. Customer Due Diligence (CDD)
 

We apply risk-based Customer Due Diligence measures, including:

• Verifying the identity of all customers using independent and reliable documents or data

• Assessing customer risk based on factors such as service type, transaction behavior, and country of origin

• Requesting proof of origin of funds and additional enquiries regarding the wallets, senders and beneficiaries of a crypto asset transaction

• Conducting Enhanced Due Diligence (EDD) for high-risk clients, including politically exposed persons (PEPs) and clients from high-risk jurisdictions

• Performing ongoing monitoring of customer activity to detect anomalies or suspicious behavior
   

3. Restricted and High-Risk Jurisdictions
 

Evendough does not establish or maintain business relationships with individuals or entities located in:

• Jurisdictions subject to broad international sanctions

• Countries or regions designated as high-risk or non-cooperative by international bodies

• Locations appearing on the Evendough’s internal list of blacklisted jurisdictions
   

We reserve the right to update or amend these restrictions as part of our ongoing risk management and regulatory compliance obligations.
 

4. Transaction Monitoring and Reporting
 

We employ both automated and manual monitoring tools to detect unusual or suspicious activity. All relevant transactions are reviewed in accordance with applicable thresholds and risk indicators.

Suspicious transactions are escalated internally and, when appropriate, reported to the designated financial intelligence or regulatory authority in the relevant jurisdiction.
 

5. Recordkeeping
 

We maintain detailed records of customer due diligence, transaction history, and internal compliance actions in accordance with the requirements of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and any other applicable regulations. 
 

All records - including identification documents, beneficial ownership information, STR-related files, transaction history, and relevant correspondence - are retained for a minimum of five (5) years, or for any longer period required by applicable law. 

Records are stored securely, protected against unauthorised access, and made available to FINTRAC or other competent authorities upon lawful request. 
 

6. Compliance Governance and Training
 

Evendough has appointed a dedicated Compliance Officer responsible for implementing AML/CTF controls and overseeing adherence to applicable regulatory requirements. Staff receive ongoing, role-specific training on AML/CTF obligations, red flags, and internal reporting procedures to ensure effective identification and escalation of potential financial crime risks.
 

7. Zero Tolerance Approach
 

Evendough maintains a strict zero-tolerance policy for money laundering, terrorist financing, and related offenses. Violations of this policy may result in account suspension or closure and reporting to the  relevant authorities.